To: Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Description: Final Revised Guidelines

Summary

The Office of the Comptroller of the Currency (OCC) is amending its enforceable guidelines relating to recovery planning standards (guidelines) for insured national banks, insured federal savings associations, and insured federal branches (banks) in order to limit the application of the guidelines to the largest, most complex banks and thereby provide regulatory burden relief to smaller, less complex institutions.

Note for Community Banks

The final revised guidelines will not apply to community banks.

Highlights

The final revised guidelines increase the average total consolidated assets threshold for applying the guidelines to banks from $50 billion to $250 billion. This change will reduce the number of banks to which the guidelines apply from 25 to 8, based on the most recent data available.

The final revised guidelines decrease from 18 months to 12 months the time within which a bank should comply with the guidelines after the bank first becomes subject to the guidelines.

Background

The 2008 financial crisis provided valuable lessons about the need for financial institutions to have strong risk governance frameworks, including plans for how to respond to and recover from the financial effects of severe stress. This was particularly true for larger, more complex banks, given the potential they pose for systemic risk. In response to these lessons, on September 29, 2016, the OCC published the guidelines establishing minimum standards for recovery planning by banks with average total consolidated assets equal to or greater than $50 billion.

On September 19, 2018, the OCC published a proposal to amend the guidelines by increasing the average total consolidated assets threshold for applying the guidelines from $50 billion to $250 billion. The final revised guidelines adopt the amendments as proposed without change. This change is consistent with providing necessary and appropriate burden relief to the affected banks while retaining the guidelines for the largest, most complex banks. The final revised guidelines also decrease from 18 months to 12 months the time within which a bank should comply with the guidelines after the bank first becomes subject to the guidelines. Additionally, the final revised guidelines make technical amendments to remove outdated compliance dates.